Continuing learners from last academic year who do not appear in this year’s ILR
A funding monitoring report identifies records and patterns that DfE wants providers to investigate and be able to explain. Appearing on one does not by itself mean a record is wrong. Many flagged records are correct and simply need their evidence produced; others turn out to need a correction.
Where this comes from
Every word below is DfE’s own, read from the published guidance on 19 September 2026. Nothing in this section was written by FEFunding.
Summary
Your current year’s ILR must include any learning aims which were reported as continuing in the previous year’s final ILR return, even if the actual end date is in the previous funding year. Aims are identified as continuing when the Completion status is code 1.
Failure to report timely and accurate withdrawals data in your previous year’s R14 return may have resulted in a funding overclaim. It may also affect your qualification achievement rates (QARs).
Funding streams reviewed
- adult skills fund (formula-funded provision)
- apprenticeships (from 1 May 2017)
- advanced learner loans
- 16 to 19 study programmes
- T Levels
What you need to do
You must report this data to us. You must report all withdrawals within three months of the learner finishing and by the final collection of the funding year.
What we will do
We may contact you in-year to understand the reasons for this data error and ensure data is reported accurately. If correcting this data triggers FRM27, then we will recover any funding overclaim from that report for errors that remain in your R14 data return.
Changes from previous funding year
None
What this means in practice
This section is FEFunding’s explanation, not DfE’s wording. It was drafted with AI assistance against the official guidance above. Its approval is pending confirmation, so it is not yet shown as reviewed by a person. Where it differs from the Department’s own words, the Department’s words are the authority.
In plain English
Last year you told DfE these learners were still on their course. This year they are not in your data at all. DfE wants to know what happened to them. Usually it means a withdrawal was recorded late, but sometimes the learner really is still there and the aim was simply left out of this year's return.
Based on FRM06 Summary.
Working knowledge
An aim reported with Completion status code 1, continuing, in the previous year's final ILR return must appear in the current year's ILR, even if its actual end date falls in the previous funding year. DfE states that failing to report timely and accurate withdrawals in the previous R14 may have caused a funding overclaim, and may also affect qualification achievement rates.
Based on FRM06 Summary.
Technical detail
The comparison is between aims carrying Completion status 1 at the previous R14 and the aims present in the current year's return. DfE's instruction is that you must report the data, and that all withdrawals must be reported within three months of the learner finishing and by the final collection of the funding year. DfE also notes that if correcting this data triggers FRM27, recovery follows from that report for errors remaining at R14.
Based on FRM06 What you need to do; FRM06 What we will do.
Why this report exists
An aim that was continuing at the end of one year and then vanishes leaves the previous year's funding unexplained. The report closes that gap by asking what happened between the two returns.
Based on FRM06 Summary.
What DfE is identifying
Aims recorded as continuing at the previous year's final return which are absent from the current year's ILR.
Based on FRM06 Summary.
Does appearing here mean something is wrong?
Not necessarily, but it does mean something is missing. Either the aim should be in this year's return and is not, or the learner left and that withdrawal was recorded after the previous year closed. The first is a reporting omission, the second is a timing problem, and they need different answers.
Based on exception-is-not-error.
Legitimate reasons for appearing
- The learner is genuinely continuing and the aim has been omitted from the current return in error, which is a reporting problem rather than a funding one.
- The learner transferred to another provider and the withdrawal was recorded correctly but after the previous year's final return had closed.
- For an apprenticeship, the learner went on a break in learning rather than withdrawing, and the record does not reflect that.
Based on break-in-learning-vs-withdrawal; completion-status-and-outcome.
Data or process problems that can cause it
- A withdrawal was known about before the previous year closed but not entered until afterwards.
- The learner was removed from the current year's enrolment rather than being carried forward as continuing.
- A break in learning was recorded as a withdrawal, or a withdrawal as a break, so the aim is not where either party expects it.
Based on break-in-learning-vs-withdrawal; mis-generates-the-ilr.
What to check first
- Establish whether the learner is actually still in learning with you today. That single answer separates a missing aim from a late withdrawal.
- Check the previous year's final return to confirm the aim really was reported as continuing.
Based on completion-status-and-outcome.
Working through it
- Take the aim and find the learner in the student record system, not in the ILR.
- Establish the learner's real status: still attending, left, transferred, or on a break in learning.
- If still attending, find out why the aim is absent from the current year's return rather than assuming the learner left.
- If they left, find the date they actually finished and when the withdrawal was entered.
- Compare those two dates. The gap between them is the thing DfE is asking about.
- If the withdrawal belongs in the previous year, expect the correction to surface on FRM27, which DfE states explicitly.
Based on FRM06 Summary; FRM06 What we will do.
ILR fields involved
- LearningDelivery.CompStatus
- LearningDelivery.LearnActEndDate
- LearningDelivery.WithdrawReason
- LearningDelivery.LearnAimRef
Based on completion-status-and-outcome; FRM06 Summary.
Related ILR validation rules
- CompStatus_03
- WithdrawReason_03
Based on CompStatus_03; WithdrawReason_03.
Related PDSAT reports
- A-510
- A-505
- B-005
Based on A-510; A-505; B-005.
Returns this relates to
- R14
Based on FRM06 Summary.
Funding implications
DfE states that failing to report timely and accurate withdrawals in the previous year's R14 may have resulted in a funding overclaim. Where correcting the record moves a withdrawal back into the previous year, DfE says recovery is handled through FRM27.
Based on FRM06 Summary; FRM06 What we will do.
Audit and assurance implications
The question is when you knew the learner had left. A withdrawal entered months after the event, with nothing showing when it became known, is difficult to explain and is a common query.
Based on evidence-must-be-contemporaneous.
Achievement rate implications
DfE states that failing to report timely and accurate withdrawals may affect qualification achievement rates. When a withdrawal is recorded changes whether the aim counts in the rate, so a late withdrawal is not a neutral administrative delay.
Based on FRM06 Summary; withdrawal-timing-affects-performance.
Evidence to look for
- Attendance or engagement records showing whether the learner was still participating.
- The date the withdrawal was notified internally, and the date it was entered into the system.
- For a transfer, the confirmation from the receiving provider or the learner.
- For an apprenticeship, the break in learning agreement and its dates.
Based on evidence-must-be-contemporaneous; break-in-learning-vs-withdrawal.
If the data is wrong
- If the learner is continuing, include the aim in the current year's return so the record is complete.
- If the learner withdrew, record the withdrawal with the date they actually finished rather than the date you found out.
- Correct it in the source system and regenerate the ILR, so the same omission does not return at the next generation.
Based on FRM06 What you need to do; correct-the-source-not-the-return.
If the data is right
- Record what the learner's status actually was and what confirmed it, so the absence from the return is explainable.
- Where a withdrawal was late, record when it became known and why it could not be entered sooner.
Based on change-evidence-matters.
Stopping it recurring
- Reconcile the previous year's continuing aims against the current year's enrolments at the start of the year, while it is still cheap to fix.
- Bring withdrawal notification and withdrawal recording closer together, since DfE requires reporting within three months of the learner finishing and by the final collection of the year.
Based on FRM06 What you need to do; final-return-closes-the-year.
Questions an MIS manager should ask
- How long does it take us, on average, between a learner stopping attending and the withdrawal reaching the ILR?
- Do we check the previous year's continuing aims against this year's enrolments, and when?
- How do we tell a break in learning from a withdrawal in our own records?
Based on withdrawal-timing-affects-performance.
Questions a finance director should ask
- How many of these are late withdrawals that will surface as recovery through FRM27, and what is the likely scale?
Based on FRM06 What we will do.
What a good answer sounds like
- A good answer gives the learner's actual status, the date it changed, and the date we recorded it, and can show where each came from.
- A weak answer is that the learner must have left, with no record of when anyone established that.
Based on change-evidence-matters.
Related Academy learning
- withdrawals-and-breaks
- year-end-close
- qar-explained
Based on withdrawal-timing-affects-performance.
Funding streams this report reviews
DfE also names advanced learner loans. The Academy has no section for that stream yet, so it is listed here as published rather than mapped onto something only approximately similar.
FRM06 in other funding years
Working through it in your own system
- Read the official wording for this report and note exactly which records it identifies.
- Find those records in your own data using the fields the report names.
- For each one, decide whether the record is correct and simply needs its evidence produced, or genuinely wrong.
- Trace a wrong record back to the entry in your source system that produced it, rather than to the file it appeared in.
- Correct it at that entry, regenerate and resubmit.
- Keep the evidence and the reason for the change together, so the record is explainable at audit.
The Academy has no verified supplier guidance for this report yet. Menu locations differ between product versions and between colleges on the same version, so we do not publish navigation we have not confirmed. The steps above are what has to be true in the data, which is the same in every system.
If the record does turn out to be wrong. Correct the record in the system where the data is entered, then regenerate the ILR file and resubmit it. Editing the generated file directly removes the symptom and leaves the cause in place, so the same record returns at the next submission with nobody expecting it. Keep a note of what was changed and why: that note is what makes the correction explainable later.